GFSC Thematic Review of AML BRAs – check sheet to consider sufficiency and suitability
The GFSC issued [15th December 2022] its report on the thematic review of business risk assessments ON money laundering and terrorist financing
- The thematic was undertaken to assess more than 100 licensed and registered firms [across all sectors] and how well firms identified and assessed these risks to their businesses.
- The results were positive, demonstrating that most Business Risk Assessments met Bailiwick's regulatory requirements.
CONSIDERATION OF THE SUFFICIENCY AND SUITABILITY OF YOUR BRA
The GFSC noted that
- The quality of BRAs was considerably higher where firms had drawn on their firm-specific MI,
- With most of the BRAs assessed as not suitable or sufficient largely because they lacked detail and were overly generic.
- And as evidenced by a proportion of firms' BRAs, further improvement in the identification and recording of TF risks will assist in Bailiwick's collective efforts to counter the ever-present risk.
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